Toronto Training Session Survey Results – April 29, 2015

On April 29th, 2015, we hosted our 2nd CMSBA Training Session at Snell Hall, Toronto, ON. We had approximately 100 attendees. Below are the survey results plus comments from the event:

Section 1: Multiple Choice and Yes/No Questions

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Section 2: Most Pressing Concerns and Issues Members Face with Regard to Their Businesses

Banking (14)

  • Establishing/maintaining relationships (12)
  • Open bank accounts (5)
  • Banking in the USA
  • Beneficial ownership for commercial clients: public sources

De-banking/De-risking (11)

  • Lack of government/agency support to combat de-banking in Canada (2)

Regulations (2)

  • Clarification of FINTRAC Regulations (8)
  • FINTRAC reporting requirements. E.g.) what information required to file? (5)
  • Complicated paper works for employees which decreases productivity
  • Industry input on regulation and policies
  • Possibility of being a self-regulating industry (accreditation process)
  • Exceptions to policies


  • High risk clients/suspicious transactions/third party determination (4)
  • Fraud prevention
  • IT Security

Compliance Cost (10)

  • Insurance (2)
  • Cost of audit (every 2 years)
  • MSB related fees for small MSBs


Agent/principal establishments (2
Agent supervision (2)
Reporting regulatory requirements as an agent (4)


From large and unregistered MSBs (4)
Types of services we can introduce
Fund receiving solutions
Oversea incoming wire

Training session (3)
US/EU sanctions – Russia
How to determine if my business is an MSB
Section 3: Suggested Topics for Future Sessions
Banking/De-Risking (7)

Bank relationships (5)
Possibility of inclusion to Canadian Payment systems without having to use traditional banks
Implementation of the “Business Relationship” Model
MSB reputation affecting business (MSBs viewed as high risk) (5)


EDD workshop for small businesses (2)
Compliance training (4)

Cost-saving techniques/technology

Managing audit/examination costs (3)
Technology solutions to help make monitoring easier, more effective, cost effective and customer friendly
Providers of software systems that aid AML/POS issues
MSB Software

Policies and Procedures

Ways to move forward as a group universally
Learn more about updates announced by USA (2)
Updating on OSC reporting and registration requirements (2)
How to implement effective customer ID program
How to document exceptions to policies
Reporting Requirements/Record Keeping (2)
Agent agreement reviews
Importance of internal review and what issues to be considered

Regulation/FINTRAC (6)

Clarification of FINTRAC Regulations (9)
Business relationship requirement of FINTRAC (2)
Question session with FINTRAC to be extended (4)
Have top banks come and speak about their requirements
Recent changes to the PCMLTFA Regulations and what they mean for MSBs and their customers
How do MSBs compare to Banks regarding compliance? (2)


Bitcoin: risks and challenges with virtual currencies
Challenges in taking on clients who deal with prepaid cards

Risk Assessment/ AML(10)

Learn more about risk assessment
AML/fraud prevention (2)
Suspicious transactions report (2)
Self-Prepared Risk Assessment

CMM (2)
Source of funds – how to use source of funds in operation
Forum to explore MSB’s issues/advices (2)

Section 4: General Comments

“CMSBA’s website needs improvement, event registration is very primitive and basic. We could use other “event registration” websites available on Internet instead of having it in CMSBA website.”

“Possibility of having afternoon training sessions. 8am is a difficult time for those of us having to travel 2-3 hours to get downtown.”

“International Association of MSB’s presentation (Ken Saul) was very informative. Happy to see the association making strides internationally.”

“I recommend you to take one step forward and collect every MSB member reasonable yearly fee to hire full time employee for the Association (CMSBA).”

“Great interaction among the MSB’s comtinued communication will help to align what is expected."

“More time for FINTRAC presentations they seem to generate the most questions.”

“Association should strive to have standards and ??? of maturity. Self-regulation is critical to the survival of MSBs.”

“Website should have storage for materials and presentations for members.”

“It is understood that an individual cannot reside within a P.O. box and that authorities can’t collect said individual at a P.O. box. However, why does the government accept P.O. boxes for valid government issued photo I.D. such as driver licenses and passports?”

“What is the difference between CMM 3 and 4 regular base-line US. Integrated?”

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